CSR POLICY

CORPORATE SOCIAL RESPONSIBILITY

Pyrotech Electronics Pvt. Ltd. (hereinafter referred as “Pyrotech”) has undertaken/shall continue to undertake appropriate Corporate Social Responsibility (CSR) measures having direct, measurable and positive economic, social, and environmental impact on the community with particular emphasis on the local area and areas around where it operates.

Guiding Principles: Pyrotech in its continuous efforts to positively impact the society, especially the areas around its sites and offices, has formulated policies for social development that are based on the following guiding principles:

• Honour the spirit of law and be a responsible corporate citizen.
• Pursue growth through harmony with the community via innovative management techniques.
• Adopt an approach that aims at achieving a greater balance between social development and economic development.
• Work towards elimination of all barriers for the social inclusion of disadvantaged groups – such as the poor, socially backward, differently abled and others.
• Develop practices aimed at inclusive growth.
• Thrust on Environment Protection.

2.2 Applicability: This CSR Policy is applicable to Pyrotech, which is mandated with the CSR expenditure obligations as per Sec. 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014, as amended from time to time.

2.3 Focus Areas: Pyrotech CSR areas target inclusive growth of all stakeholders under various categories, mentioned under Sch. VII of The Companies Act, 2013. These primarily fall under drinking water, sanitation, education, healthcare, social development, livelihood opportunities and environment protection. These are:

• Rural Development Projects
• Healthcare including sanitation and drinking water
• Education, Vocational Skills & Scientific Research (incl. Educational Infrastructure)
• Gender Equality & Women Empowerment (Incl. Old age homes)
• Environmental Sustainability
• Other items as may be prescribed from time to time under Sch. VII of The Companies Act, 2013.

Governance Structure
3.1 A three-tier governance structure is responsible for implementing CSR activities at Pyrotech. These include the CSR Committee of the Board, Corporate CSR Team, and Operational CSR Teams.

Composition of CSR Committee:
The CSR Committee shall consist of the following:

• Virendra Prakash Rathi
• Pratap Singh Talesara
• Chandra Prakash Talesara

3.2 Roles and Responsibilities

3.2.1 CSR Committee shall consist of three or more directors. CSR committee shall be responsible for:

• Formulation of CSR Policy.
• Regular monitoring of implementation of CSR policy.
• Identify key initiatives pursuant to the CSR policy.
• Recommend to the Board CSR expenditure to be incurred.
• Recommend to the Board, modifications to CSR policy as and when required.

3.2.2 Dedicated CSR team shall be constituted at Corporate Office for implementing the CSR Policy. Corporate CSR Team located at Udaipur shall be responsible for:

• Implementation of CSR Policy.
• Identify Key Result Areas (KRAs) and Key Performance Indicators (KPIs) to be tracked at Corporate level and Operational (plant/project location) level.
• Develop Annual Operating Plan (AOP) and targets against each of the identified KPIs at Corporate and Operational level. (to be developed on a bottom-up basis).
• Secure necessary approvals for CSR AOP
• Facilitating allocation of funds along with relevant SPVs/Operations Team.
• Monitoring of CSR projects on a quarterly basis to establish effectiveness of CSR efforts and report the same to the CSR Committee.
• Compilation of Information & Preparation of annual reports on CSR activities and. presenting the same to the CSR Committee.
• Organize Training programmes for CSR staff.
• Any other activity necessary to ensure achievement of Pyrotech Electronics CSR mission

3.2.3 Operational CSR Team located at respective plant / project locations is responsible for:

• Provide Inputs for the CSR Policy Design.
• Bottom-up preparation of CSR AOPs and identification of annual targets against KPIs.
• Implementation of CSR Action Plans.
• Conduct Needs Assessment Survey.
• Own the CSR Programmes implemented and monitor effectiveness of CSR initiative delivery.
• Monthly reporting on progress of CSR interventions.
• Any other activity necessary to ensure achievement of Pyrotech Electronics CSR mission

3.2.4 To maintain continuity of community related interventions / programmes initiated during the project development stage, team members engaged in such activities would be drawn in as CSR team members at the project execution / operation stage, wherever possible and augmented if necessary.

3.2.5 Depending on interventions / programmes, external experts shall be engaged on a contract basis for development of baseline data, planning, implementation, monitoring effectiveness of CSR initiatives, etc.